Community Impact Assessment Form For a summary of this Community Impact Assessment, click here Title of Community Impact Assessment (CIA): Redefined Offer for Vulnerable People – Proposal for Welfare Right & Debt Advice Services Directorate: Community Health & Social Care Date of assessment: May 2014 Names and roles of people carrying out the community impact assessment. (Please identify Lead Officer): Mike Wright, Head of Housing Choice Section A – What are you impact assessing? (Indicate with an “x” which applies):A decision to review or change a service A strategy A policy or procedure A function, service or project X Are you impact assessing something that is?:New Existing Being reviewed Being reviewed as a result of budget constraints X X 1 Summary Brief summary of proposal The CIA is being conducted to assess the impact of the proposal to reduce funding to the Welfare Rights & Debt Advice Service (WRDA) by £346k. This follows the work on developing the city-wide review of Welfare Rights & Debt Advice delivery. How did you approach the CIA and what did you find? We approached the CIA from the point of building on the existing comprehensive consultation with many user groups during the recent review if WRDA services. From this, we have been able to better assess the proposal to ensure that impacts of the proposal are minimised. For example, the proposal maintains front line service delivery to vulnerable groups across the city as far as possible within a reduced financial envelope. We understand that there are common features between the client groups of partner services such as the CAB and housing providers and that many have used both in the past. A copy of this assessment will be made available to Trades Unions and the Council will continuously monitor the impact of its proposals and where possible take measures to mitigate, reduce or eliminate any anticipated and adverse impact of the proposals. What are the main areas requiring further attention? The main areas for attention or monitoring are ensuring that the remaining resources in the city is managed effectively, and that there are effective and efficient mechanisms to provide better advice at the first point of contact in a joined-up fashion. It will also be essential to monitor the impact of this change on remaining services in the city, to maximise the impact of resources during a period of continuing welfare reform. Summary of recommendations for improvement Improved monitoring of retained management Ongoing training and skills development programme for retained management 2 Describe the area you are impact assessing and, where appropriate, the changes you are proposing? The CIA is being conducted to assess the impact of the proposal to reduce funding to the Welfare Rights & Debt Advice Service (WRDA) by £346k. This follows the work on developing the city-wide review of Welfare Rights & Debt Advice delivery. This proposal is being raised because of the need to deliver services more efficiently due to a budget pressure confirmed by Budget Strategy Group. This is at a time of likely increases in demand due to the current economic climate and the Welfare Reform Programme. It is anticipated that there will be increased demand for advice and support services and the role of the local authority will be critical to building personal financial resilience, assisting the prevention of homelessness, combating family poverty, and linking residents to training and work opportunities. This CIA is intended to assess the impacts (both positive and negative) of the proposed changes to the service delivery arrangements in these service areas. This is within a context of: Continuing budget pressure on SCC Increased indebtedness Increased arrears of rent and Council Tax Increased use of high interest lenders and loan sharks Increased homelessness presentations and homes at risk of repossession. Increased pressure on household finances. Higher levels of depression and mental health problems. Increasing reliance on partner delivery and co-operation This means that the City Council has to reorganise the way that advice services are delivered to provide a more resilient service. The changes proposed focus strongly on the way in which services are managed, to protect front line delivery as far as possible, to respond to potential increases in demand. The council will need to ensure that there is sufficient knowledge and skills in its retained management structure to provide effective management to staff carrying out front line roles. 3 Section B – Is a Community Impact Assessment required (Screening)? Consider what you are impact assessing and mark “x” for all the statement(s) below which apply Service or policy that people use or which apply to people (this could include staff) Discretion is exercised or there is potential for people to experience different outcomes. For example, planning applications and whether applications are approved or not Concerns at local, regional or national level of discrimination/ inequalities Major change, such as closure, reduction, removal or transfer Community, regeneration and planning strategies, organisational or directorate partnership strategies/ plans Employment policy – where discretion is not exercised Employment policy – where discretion is exercised. For example, recruitment or disciplinary process X X X X X If none of the areas above apply to your proposals, you will not be required to undertake a full CIA. Please summarise below why a full CIA is not required and send this form to your directorate equality link officer. If you have identified one or more of the above areas, you should conduct a full CIA and complete this form. Equality Areas Indicate with an “x” which equality areas are likely to be affected, positively or negatively, by the proposals Age X Religion and/or belief ? Disability X Sexual Identity ? Gender (including pregnancy and maternity) X People on a low income (socio-economic inequality) X Gender reassignment ? X Race X Other (please state below) (For example carers, ex offenders) Carers and intermediaries, If any of the equality areas above have been identified as being likely to be affected by the proposals, you will be required to undertake a CIA. You will need only to consider those areas which you have indicated are likely to be affected by the proposals 4 Section C – Monitoring information C1 Do you currently monitor by the following protected characteristics or equality areas? Age Yes (Y) or No (N) Disability Y Gender (including pregnancy and maternity) Y Gender Reassignment N Race Y Religion and/or belief Y Sexual Identity N People on a low income (socio-economic inequality) Y Other (please state) (For example carers, ex offenders) Y If no, please explain why and/ or detail in the action plan at Section E how you will prioritise the gathering of this equality monitoring data. Y We are intending to amend our monitoring forms to ask further information on this question. We are intending to amend our monitoring forms to ask further information on this question. 5 Section C (continued) – Consultation C2 Are you intending to carry out consultation on your proposals? Yes If “no”, please explain your reason(s) why If “yes”, please give details of your consultation exercise and results below The council has consulted about its Welfare Rights & Debt Advice proposals as part of its proposed Redefined Offer for Vulnerable Adults. It posted an initial pack to 3,221 service users and carers whose addresses it had. Approximately 8 weeks into the process it sent reminder to 3,227 service users, and published an advert about the consultation at the same time. Stakeholders were contacted and advised of the consultation and proposed changes to the service. The council received 1,832 responses to the overall consultation, of which 1,071 (58%) referred to the Welfare Rights & Debt Advice proposals. 342 (32%) of the responses were in agreement with the proposal. Is it fair that the council reduces the funding available for this service so that some people will need to seek alternative support for themselves? Of all those who responded about Welfare Rights & Debt Advice, 32% (342) either strongly agreed or agreed that it is fair to expect people to pay. However very few users agreed (7%, 20), or carers (10%, 8) and family or friends of users (6%, 6), confirming that overall that most people disagreed or strongly disagreed that it is fair. Those who identified themselves as disabled people agreed less than those who identified themselves as non-disabled, with only 28% (126) of all disabled respondents supporting it, compared to 39% (128) of non-disabled respondents. There was less difference between disabled users 8% (8) who agreed and 10% (9) non-disabled users and between disabled carers (12%, 4) compared to non-disabled carers (11%, 4). There was a greater difference amongst disabled friends or family of service users (3%, 1) compared to non-disabled family or friends of users (10%, 5). Agreement was generally lower amongst those aged 45-64 (27%, 71) and 25-44 (27%, 40) compared to those aged over 65 (39%, 136). It was lowest amongst those aged 25-44 who were users (6%, 4), those aged 45-64 who were carers of users (7%, 2) or those aged 65+ who were family of friends of users (7%, 1). The proportions of men and women who strongly agreed and agreed that it is fair were very similar at between 36% (103) and 32% (153). Users, carers of users and family or friends of users were much less likely to agree for either gender, although men were slightly 6 more in favour. The greatest agreement for these groups was just 16% (4) for male carers of service users and the least agreement was less than 1% (4) of women who were family or friends of users. Approximately 46% (457) of respondents indicated that they had a religious belief. Of these 49% (154) strongly agreed and agreed that it is fair, which is more than those who indicated that they had no religious belief (27%, 83) but that it is fair. The majority of those who disclosed their religion (92%, 472) were Christian. 35% (164) of these agreed that it was fair. For other religions, there were significantly smaller proportions, with the Jewish faith (11%, 1), other religions (32%, 6) and Muslims (17%, 2). Three quarters of respondents revealed their ethnic heritage (76%, 785), and of those who did 93% (732) were White British and 34% (251) strongly agreed or agreed with the proposal. This compares to 66% (8) of the much smaller number of people who identified themselves as White Irish and 23% (3) people who identified themselves as mixed heritage, who supported the proposal. Many respondents did not disclose their sexual identity (30%, 437). Of the 31% (317) who strongly agreed or agreed that it is fair that the council reduces the funding available for this service so that some people will need to seek alternative support for themselves, 61% (194) were heterosexual/ straight, 3% (8) gay men, 3% (8) bisexual and 1% (2) lesbian/ gay women. Q31. If you have received this service (Welfare Rights & Debt Advice), could you get similar support from elsewhere in the future? From family From friends and neighbours From a community service, group or charity Other (combined variations on the above options) Other (please specify) Total You (Nos) 44 8 50 57 0 159 You (%) 28% 5% 31% 36% 0% 100% N.B. - these figures include responses only if Q30 (Welfare Rights & Debt Advice) was answered. Of the 159 responses, the remainder being ‘not answered’, the single most common sources of similar support from elsewhere in the future was ‘from a community service, group or charity’ at 31% and ‘from family’ at 28%. Formal consultation will take place with all staff teams with in the WRDA service. There will also be formal consultation with the Trade 7 Unions. This consultation will take the form of collective and individual meetings made available to all staff. Assistant Mayors will also be consulted through the Workforce Panel process. Any employees affected by the changes will be managed in line with the Workforce Change policy arrangements. In line with the Council’s approach to creating capacity for those at risk of redundancy every effort will be made to identify reasonable suitable alternative employment throughout the process. Section C (continued) – Analysis C3 What information has been analysed to inform The impact of the Welfare Reform Act on citizens Salford city council and other the content of this CIA? What were the findings? agencies has already been widely scoped by the WRDA service: Please include details of, for example, service or employee monitoring information, consultation findings, any national or local research, customer feedback, inspection reports, and any other information which will inform your CIA. Please specify whether this was existing information or was specifically in relation to this equality analysis and CIA process Welfare Reform Act 2012 and Impact on Salford - FISG briefing paper .doc An extensive consultation process has already recently been carried out in respect of the city-wide WRDE Delivery Model. This included: Staff engagement session – May 2014 City Mayor/ Assistant Mayor agreement to consult – February 2013 Initial consultation at CH&SC DCSC – 11th March 2013 WRDA staff team meeting – 25th March 2013 (Initial response deadline 26th April) Adult Social Care Scrutiny Select Committee consultation – 27th March 2013 Financial Inclusion Group Consultation – 28th March 2013 Consultation with CMT – April/May 2013 User Development Group and Communities of Interest consultation meetings – May/ June 2013 Elected member consultation – June 2013 Partner agency consultation – June 2013 Public consultation launch in Life in Salford – 3rd June 2013 WRDA/ Housing advice staff team workshop – 20th June 2013 8 Report on consultation/ community impact assessment to Assistant Mayor – 10th July Final proposal to City Mayor for approval – September 2013 Section D – Potential impacts and how these will be addressed Could your proposals have a Yes (Y) differential impact relating to age equality Are your proposals discriminatory on the grounds of age? Will people within certain age ranges not be getting the outcome they need? Will people within certain age ranges be disadvantaged as a result of your proposals? If the impact is negative, how will it be reduced or eliminated? No (N) Explain impact(s) and what evidence or data exists to support your analysis? N There proposal is unlikely to discriminate against any Salford resident on the grounds of age. The reduction in front line service delivery will be kept to the minimum possible, with increased provision of advice and assistance from partner agencies following the promotion of the city-wide model for WRDA. Proposals to increase the capacity of Gateway, Registered Social Landlords and other staff to give an agreed level of advice will provide a wider resource spread of basic face to face Welfare Rights advice and help with some form filling. The overall impact of the changes is likely to be neutral for most older people. The Welfare Reform programme is mainly aimed at people of working age, therefore older people are less impacted by the changes. However, older people are less likely to have internet access and PC literacy, so mitigating action in respect of this group will be required. Young people (18-25 yrs) will continue to be impacted by the Welfare Reform Programme. However, there will be no specific impact on this group through the proposal to integrate these service areas. SCC is anticipating an increase in demand for services from this age group, and the Council is committed to ensuring that front line and support workers from partner agencies are equipped to give accurate advice. Some young people are more likely to be able to self serve and access advice online, and vulnerable young people may also have a support worker to advise them. 9 The proposal does not change the level of resource dedicated to young people. The WRDA website contains a lot of information on welfare reform and how to get advice, and the Way to wellbeing portal will be another on line resource designed for Salford citizens to use. The new Wuu2 website managed by Integrated Youth Services will be a valuable resource for youth workers to interact with young people and provide advice and information. Overall, mitigating the impact of the reforms on this age group will depend on increasing the supply of advice that can be provided by a combination of partners such as Citizen’s Advice, Salix Homes and City West, and through support workers such as probation officers and social workers. Will the proposals mean that people within certain age ranges will experience positive outcomes? Highlight any positive impacts There is potential to develop a more joined-up service approach with potentially better access to critical advice through an integrated service. Are the proposals likely to impact on community cohesion? Is there potential to enhance relationships between people who share a protected characteristic and those who do not? Identify areas where there is potential to foster good relations No Section D (continued) – Potential impacts and how these will be addressed Could your proposals have a differential impact relating to disability equality Are your proposals discriminatory on the grounds of Yes (Y) No (N) Explain impact(s) and what evidence or data exists to support your analysis? N The proposal does not change the level of resource dedicated to this client group. It is recognised that people with disabilities have wide ranging and complex needs 10 disability? Will people with disabilities not be getting the outcome they need? Will people with disabilities be disadvantaged as a result of your proposals? If the impact is negative, how will it be reduced or eliminated? including physical, mental and sensory. This group will be impacted by welfare reform as many are in receipt of benefits which will subject to some form of reassessment over time. The proposal should not significantly reduce the availability of frontline face-to-face advice. However, there could be increased waiting times for appointments if demand increases significantly. Will the proposals mean that people with disabilities will experience positive outcomes? Highlight any positive impacts No There is potential to develop a more joined-up service approach with potentially better access to critical advice through an integrated service. Are the proposals likely to impact on community cohesion? Is there potential to enhance relationships between people who share a protected characteristic and those who do not? Identify areas where there is potential to foster good relations Section D (continued) – Potential impacts and how these will be addressed Could your proposals have a differential impact relating to gender equality (this includes pregnancy and maternity) Are your proposals discriminatory on the grounds of gender? Yes (Y) No (N) Explain impact(s) and what evidence or data exists to support your analysis? N There is no specific gender impact as a result of these proposals. 11 Will men or women, boys or girls not be getting the outcome they need? Will men or women, boys or girls be disadvantaged as a result of your proposals? If the impact is negative, how will it be reduced or eliminated? Will the proposals mean that men or women, boys or girls will experience positive outcomes? Highlight any positive impacts No Are the proposals likely to impact on community cohesion? Is there potential to enhance relationships between people who share a protected characteristic and those who do not? Identify areas where there is potential to foster good relations No Section D (continued) – Potential impacts and how these will be addressed Could your proposals have a differential impact relating to equality for people planning, undergoing or who have undergone gender reassignment? Are your proposals discriminatory for people planning, undergoing or who have undergone gender reassignment? Will people planning, undergoing or who Yes (Y) No (N) Explain impact(s) and what evidence or data exists to support your analysis? N There is no specific impact on this group as a result of these proposals. Do you have user data akin to what you mentioned about age above? If so, include. 12 have undergone gender reassignment not be getting the outcome they need? Will people planning, undergoing or who have undergone gender reassignment be disadvantaged as a result of your proposals? If the impact is negative, how will it be reduced or eliminated? Will the proposals mean that people planning, undergoing or who have undergone gender reassignment will experience positive outcomes? Highlight any positive impacts There will be an opportunity to record and monitor customers who have undergone gender reassignment to more accurately assess demand and take-up within this community. Are the proposals likely to impact on community cohesion? Is there potential to enhance relationships between people who share a protected characteristic and those who do not? Identify areas where there is potential to foster good relations No Section D (continued) – Potential impacts and how these will be addressed Could your proposals have a differential impact relating to race equality Are your proposals discriminatory on the grounds of race? Will people within certain racial groups not be getting the Yes (Y) No (N) Explain impact(s) and what evidence or data exists to support your analysis? The proposal will not discriminate on the grounds of race. It should be noted that recent consultation on the city-wide WRDA model highlighted concerns in the BME communities around welfare reform and the impact that it may have on them specifically. The main issues that the network identified were language barriers and lack of IT skills. The proposed internet advice solutions include availability in 13 outcome they need? Will people within certain racial groups be disadvantaged as a result of your proposals? If the impact is negative, how will it be reduced or eliminated? community languages and telephone advice is available through interpretation services. Salford City Council has an Arabic speaking Linkworker Service. Some change is likely to this service, and mitigating actions will be required such as those identified above. Do you have user data akin to what you mentioned about age above? If so, include. Will the proposals mean that people within certain racial groups will experience positive outcomes? Highlight any positive impacts There is potential to develop a more joined-up service approach with potentially better access to critical advice through an integrated service. Former asylum seekers are often disproportionately affected by homelessness and therefore it may be of positive benefit for them to access WRDA at this point through a more integrated service. Are the proposals likely to impact on community cohesion? Is there potential to enhance relationships between people who share a protected characteristic and those who do not? Identify areas where there is potential to foster good relations No Section D (continued) – Potential impacts and how these will be addressed Could your proposals have a differential impact relating to religion or belief equality Are your proposals discriminatory on the grounds of religion or belief? Yes (Y) No (N) Explain impact(s) and what evidence or data exists to support your analysis? There is no specific impact on religious groups as a result of these proposals. 14 Will people of certain religions or who have particular beliefs not be getting the outcome they need? Will people of certain religions or who have particular beliefs be disadvantaged as a result of your proposals? If the impact is negative, how will it be reduced or eliminated? Will the proposals mean that people of certain religions or who have particular beliefs will experience positive outcomes? Highlight any positive impacts There is potential to develop a more joined-up service approach with potentially better access to critical advice through an integrated service. Are the proposals likely to impact on community cohesion? Is there potential to enhance relationships between people who share a protected characteristic and those who do not? Identify areas where there is potential to foster good relations No Section D (continued) – Potential impacts and how these will be addressed Could your proposals have a differential impact relating to sexual identity equality Are your proposals discriminatory on the grounds of Yes (Y) No (N) Explain impact(s) and what evidence or data exists to support your analysis? The proposal will not discriminate on the grounds of sexual identity. 15 sexual identity? Will gay, lesbian and/ or bisexual people not be getting the outcome they need? Will gay, lesbian and/ or bisexual people be disadvantaged as a result of your proposals? If the impact is negative, how will it be reduced or eliminated? Will the proposals mean that gay, lesbian and/or bi-sexual people will experience positive outcomes? Highlight any positive impacts There is potential to develop a more joined-up service approach with potentially better access to critical advice through an integrated service. Are the proposals likely to impact on community cohesion? Is there potential to enhance relationships between people who share a protected characteristic and those who do not? Identify areas where there is potential to foster good relations No Section D (continued) – Potential impacts and how these will be addressed Could your proposals have a differential impact on socio economic equality (people on a low income)? Are your proposals discriminatory on the grounds of Yes (Y) No (N) Explain impact(s) and what evidence or data exists to support your analysis? The proposal does not discriminate on the grounds of socio-economic inequality. However, the customer base of these service areas is significantly of households 16 socio economic inequality? Will people on a low income not be getting the outcome they need? Will people on a low income be disadvantaged as a result of your proposals? If the impact is negative, how will it be reduced or eliminated? on low incomes, with lower levels of choice and greater commensurate pressure on their finances and economic situation. Therefore, the impact of any service change will be felt disproportionately by this group. It should be noted that the new model for the WRDA service promotes a combination of early intervention through signposting or information at an early stage through the council and its partners such as the Citizens Advice Bureaux, Registered Social Landlord’s, and through on-line resources. The service(s) will need to continue to develop and promote self help tools and assisted information, but the ability to marry this with access to face to face and telephone access to advice is essential for low income residents and this will be expanded through early triage at Gateways and through the contact centre. Referrals to specialist advisers in WRDA and CAB will still be available, however if demand increases significantly then there could be delays in obtaining appointments. It is also important that people are able to obtain affordable credit when they need it. The proliferation of pay day loan and pawn shops will be discouraged, and the council will actively support and promote credit unions as a means of managing money. Will the proposals mean that people on a low income will experience positive outcomes? Highlight any positive impacts There is potential to develop a more joined-up service approach with potentially better access to critical advice through an integrated service. Are the proposals likely to impact on community cohesion? Is there potential to enhance relationships between people who share a protected characteristic and those who do not? Identify areas where there is potential to foster good relations No 17 Section D (continued) – Potential impacts and how these will be addressed Could your proposals have a Yes (Y) differential impact relating to any other equality groups, for example, carers, ex offenders? Are your proposals discriminatory in relation to any other groups? Will people within any other groups not be getting the outcome they need? Will people within any other groups be disadvantaged as a result of your proposals? If the impact is negative, how will it be reduced or eliminated? No (N) Explain impact(s) and what evidence or data exists to support your analysis? The proposal does not discriminate on other grounds of equality Previous consultation with user groups has indicated that there will be increased pressure on intermediaries/ appointees who may be carers, family or friends. This group can often feel isolated, and will face increased pressures through the changes to welfare benefits and the need to understand the implications for the person they provide care for. Carers sometimes have less time to seek face to face advice, so it will be important that they have access to telephone and on-line services, and home visits where necessary. Salford Carers Centre provides a range of services for adult, young adult and young carers, and the council will continue to work closely with them, and help them to monitor the impact of the changes on this group. Will the proposals mean that people within any other groups will experience positive outcomes? Highlight any positive impacts There is potential to develop a more joined-up service approach with potentially better access to critical advice through an integrated service. Are the proposals likely to impact on community cohesion? Is there potential to enhance relationships between people who share a protected characteristic and those who do not? Identify areas where there is potential to foster good relations No 18 Section E – Action Plan and review Detail in the plan below, actions that you have identified in your CIA, which will eliminate discrimination, advance equality of opportunity and/ or foster good relations. If you are unable to eliminate or reduce negative impact on any of the equality areas, you should explain why Impact (positive or negative) identified Proposed action Person(s) responsible Continued city wide provision of advice by partners Common referral protocol to be approved Integrated Service Management Effective integration of services at management level Common training and development programme CHSC Senior Managers Where will action be monitored? (e.g. Directorate Business Plan, Service Plan, Equality Action Plan) Business Plan and Partner forums Target date Required outcome 01 December 2014 More efficient referrals and reduced duplication Supervision sessions 01 January 2015 Management services able to perform effectively and meet service goals Could making the changes in any of the above areas have a negative effect on other groups? Explain why and what you will do about this. N/A Review Your CIA should be reviewed at least every three years, less if it has a significant impact on people. Please enter the date your CIA will be reviewed ……………………..You should review progress on your CIA action plan annually. 19 Section F – Summary of your CIA As your CIA will be published on the council’s website and accessible to the general public, a summary of your CIA is required. Please provide a summary of your CIA in the box below. Summary of Community Impact Assessment How did you approach the CIA and what did you find? We approached the CIA from the point of building on the existing comprehensive consultation with many user groups during the recent review if WRDA services. From this, we have been able to better assess the proposal to ensure that impacts of the proposal are minimised. For example, the proposal maintains front line service delivery to vulnerable groups across the city as far as possible within a reduced financial envelope. We understand that there are common features between the client groups of partner services such as the CAB and housing providers and that many have used both in the past. A copy of this assessment will be made available to Trades Unions and the Council will continuously monitor the impact of its proposals and where possible take measures to mitigate, reduce or eliminate any anticipated and adverse impact of the proposals. What are the main areas requiring further attention? The main areas for attention or monitoring are ensuring that the remaining resources in the city is managed effectively, and that there are effective and efficient mechanisms to provide better advice at the first point of contact in a joined-up fashion. It will also be essential to monitor the impact of this change on remaining services in the city, to maximise the impact of resources during a period of continuing welfare reform. Summary of recommendations for improvement Improved monitoring of retained management Ongoing training and skills development programme for retained management Section G – Next Steps Quality Assurance When you have completed your CIA, you should send it to your directorate Equality Link Officer who will arrange for it to be quality assured. Your CIA will be returned to you if further work is required. It is important that your CIA is robust and of good quality as it may be challenged 20 “Sign off” within your directorate Your directorate Equality Link Officer will then arrange for your CIA to be “signed off” within your directorate (see below). Your directorate Equality Lead Officer or other senior manager within your directorate should “sign off” your CIA (below). Name Signature Senior Manager Keith Darragh Lead CIA Officer Mike Wright Date Publishing When your CIA has been signed off within your directorate, your directorate Equality Link Officer will send it to Elaine Barber in the Equalities and Cohesion Team for publishing on the council’s website. Monitoring Your directorate Equality Link Officer will also send your CIA to your directorate Performance Officer where the actions identified within your CIA will be entered into Covalent, the council’s performance management monitoring software so that progress can be monitored as appropriate. 21